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A separate statement of claim and corresponding statement of defence filed with respect to the 1980 reassessment were amended as a consequence of a second reassessment by the Minister for that taxation year in connection with items not in issue in these appeals. ...

The written warning tax shelter promoters are mandated by paragraph 237.1(3)(c) of the Income Tax Act to display in connection with use of a tax shelter identification number is consistent with Parliament’s intent that taxpayers should participate in a tax shelter at their own peril, not at the peril of Canadian taxpayers generally. ...

In that connection, Mr. Pronovost admitted that he had not invested anything in the grocery store, but he said that he would not have been entitled to the profits if the store had generated any. [20]          Decisions on expenses were always made by Mr. ...

(vii.1) reasonable allowances for the use of a motor vehicle received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling in the performance of the duties of the office or employment,... ...

Reasons for Judgment Bowie, J.T.C.C. [1] The issue in this appeal is whether the Appellant, in computing its income under the Income Tax Act (the Act) for the 1990 taxation year, was entitled to deduct an amount of $26,089,145 as a writedown of deposits on land for development, including preliminary development costs expended in connection therewith. ...

Erich Klein, Revisor [1]           Furlong report, section 2.7, p. 23 et seq. [2]           Exhibit A-9 says "Coin du Pare-Brise". [3]           See Exhibits A-8 and A-9. [4]           See Exhibits A-8 and A-9. [5]           See Furlong report, pp. 31 and 32. [6]           See in this connection two decisions referred to by counsel for the appellant: Immeubles Polaris (Canada) Ltée c. ...

If that had been the case, a connection by marriage could not have been established between Mr. ...

Canadian Investment Fund (CIF) The CIF is intended to identify the dollar value of the pool of property that is considered to be used or held in connection with the Canadian business of the insurer. [4]           In the transcript of his evidence, from pages 106 to 109. [5]          .5% management fee X GWLP receivable from GWL of $49,709,601 = $248,548. [6]           The interest calculation on a demand note of $124,500,000 issued by GWLP to GWL in December 1988. ...

Here, we do not have this intimate connection. The closest reserve, the Dakota Ojibway reserve, was 100 kilometres away from Winnipeg, while the furthest away, the Keewatin reserve, was located so far north that an overnight airplane trip was required to get to Winnipeg. ...

I do not find that high degree of negligence in connection with the misstatements of business income. ...